Accessible Customer Service Policy
This policy is intended to meet the requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07 created under the authority of the Accessibility for Ontarians with Disabilities Act, S.O. 2005, c. 11, and applies to the provision of goods and services to the public or other third parties, not to the goods themselves.
All CFC goods and services shall be provided in a manner consistent with the principles of dignity, independence, integration and equal opportunity.
a) This policy applies to the provision of goods and services at premises owned and operated by the CFC.
b) This policy applies to employees, volunteers, agents, consultants and/or contractors who deal with the public or other third parties that act on behalf of the CFC, including when the provision of goods and services is by other businesses or occurs off the premises of the CFC such as in: program delivery, delivery services, call centers, vendors, drivers, catering and third party marketing agencies.
c) This policy shall also apply to all persons who participate in the development of the CFC’s policies, practices and procedures governing the provision of goods and services to members of the public or third parties.
Assistive Device– is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities.Personal assistive devices are typically devices that customers bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.
Disability – the term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:
- any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
- a condition of mental impairment or a developmental disability;
- a learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
- a mental disorder; or
- an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
Guide Dog – is a highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.
Service Animal – as reflected in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if:
- it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
- if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.
Service Dog – as reflected in Health Protection and Promotion Act, Ontario Regulation 562 a dog other than a guide dog for the blind is a service dog if:
- it is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability;
- or the person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.
Support Person – as reflected in Ontario Regulation 429/07, a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or access to goods and services.
In accordance with the Accessibility Standards for Customer Service, Ontario Regulation 429/07, this policy addresses the following:
- The Provision of Goods and Services to Persons with Disabilities;
- The Use of Assistive Devices
- The Use of Guide Dogs, Service Animals and Service Dogs
- The Use of Support Persons
- Notice of Service Disruptions
- Customer Feedback
- Notice of Availability and Format of Required Documents
- The Provision of Goods and Services to Persons with Disabilities
CFC will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity by:
- ensuring that all customers receive the same value and quality;
- allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services as long as this does not present a safety risk;
- using alternative methods when possible to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner;
- taking into account individual needs when providing goods and services; and
- communicating in a manner that takes into account the customer's disability.
- Assistive Devices
Customer’s own assistive device(s):
Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by the CFC.
In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services. For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a customer with an oxygen tank may involve ensuring the customer is in a location that would be considered safe for both the customer and business. Or, where elevators are not present and where an individual requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer.
The CFC does provide:
Barrier free washrooms in the following buildings; Cottage A/B, The Gatehouse and the Stable.
A service elevator in the Main House.
C.Guide Dogs, Service Animals and Service Dogs
A customer with a disability that is accompanied by guide dog, service animal or service dog will be allowed access to premises that are open to the public or third parties unless otherwise excluded by law. “No pet” policies do not apply to guide dogs, service animals and/or service dogs.
Food Service Areas:
A customer with a disability that is accompanied by guide dog or service dog will be allowed access to food service areas that are open to the public or third parties unless otherwise excluded by law.
Other types of service animals are not permitted into food service areas due to the Health Protection and Promotion Act, Ontario Regulation 562 Section 60.
If a guide dog, service animal or service dog is excluded by law (see examples of applicable laws below) the CFC will offer alternative methods to enable the person with a disability to access goods and services, when possible (for example, securing the animal in a safe location and offering the guidance of an employee).
Food Safety and Quality Act, 2001, Ontario Regulation 31/05: Animals not intended for slaughter or to be euthanized are not allowed in any area or room of a meat plant. It also makes an exception for service dogs to allow them in those areas of a meat plant where food is served, sold or offered for sale to customers and in those areas that do not contain animals or animal parts and are not used for the receiving, processing, packaging, labelling, shipping, handling or storing of animals or parts of animals.
The Health Protection and Promotion Act,1990, Ontario Regulation 562, normally does not allow animals in places where food is manufactured, prepared, processed, handled, served, displayed, stored, sold or offered for sale. It does allow guide dogs and service dogs to go into places where food is served, sold or offered for sale. However, other types of service animals are not included in this exception.
Dog Owners' Liability Act, Ontario: If there is a conflict between a provision of this Act or of a regulation under this or any other Act relating to banned breeds (such as pitbulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails.
Recognizing a Guide Dog, Service Dog and/or Service Animal:
If it is not readily apparent that the animal is being used by the customer for reasons relating to his or her disability, the CFC may request verification from the customer.
Verification may include:
- a letter from a physician or nurse confirming that the person requires the animal for reasons related to the disability;
- a valid identification card signed by the Attorney General of Canada; or,
- a certificate of training from a recognized guide dog or service animal training school.
Care and Control of the Animal:
The customer that is accompanied by a guide dog, service dog and/or service animal is responsible for maintaining care and control of the animal at all time.
If a health and safety concern presents itself for example in the form of a severe allergy to the animal, the CFC will make all reasonable efforts to meet the needs of all individuals.
- Support Persons
If a customer with a disability is accompanied by a support person, the CFC will ensure that both persons are allowed to enter the premises together and that the customer is not prevented from having access to the support person.
There may be times where seating and availability prevent the customer and support person from sitting beside each other. In these situations the CFC will make every reasonable attempt to resolve the issue.
In situations where confidential information might be discussed, consent will be obtained from the customer, prior to any conversation where confidential information might be discussed.
If payment is required by a support person for admission to the premises the CFC will ensure that notice is given in advance by posting notice of admission fees for support persons where the CFC fees are posted. We are allowed to charge the support person reduced or regular admission fees.
- Notice of Disruptions in Service
Service disruptions may occur due to reasons that may or may not be within the control or knowledge of the CFC. In the event of any temporary disruptions to facilities or services that customer's with disabilities rely on to access or use the CFC’s goods or services, reasonable efforts will be made to provide advance notice. In some circumstances such as in the situation of unplanned temporary disruptions, advance notice may not be possible.
Notifications will Include:
In the event that a notification needs to be posted the following information will be included unless it is not readily available or known:
- goods or services that are disrupted or unavailable
- reason for the disruption
- anticipated duration
- a description of alternative services or options
When disruptions occur the CFC will provide notice by one or more of the following methods:
- posting notices in conspicuous places including at the point of disruption, at the main entrance and the nearest accessible entrance to the service disruption and/or on the CFC’s website;
- contacting customers with appointments;
- verbally notifying customers when they are making a reservation or appointment; or
- by any other method that may be reasonable under the circumstances.
The CFC shall provide customers with the opportunity to provide feedback on the service provided to customers with disabilities. Information about the feedback process will be readily available to all customers and notice of the process will be made available by request to the Chief Human Resources Officer contact information below).
Feedback forms along with alternate methods of providing feedback such as verbally (in person or by telephone).
Customers can submit feedback in person, by email, or by telephone to:
Chief Human Resources Officer, CFC
Canadian Film Centre
2489 Bayview Avenue
Toronto, ON M2L 1A8
Customers that provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.
Training will be provided to:
- all employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of the CFC.
As reflected in Ontario Regulation 429/07, regardless of the format, training will cover the following:
- A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005.
- A review of the requirements of the Accessibility Standards for Customer Service, Ontario Regulation 429/07.
- Instructions on how to interact and communicate with people with various types of disabilities.
- Instructions on how to interact with people with disabilities who:
- use assistive devices;
- require the assistance of a guide dog, service dog or other service animal; or
- require the use of a support person (including the handling of admission fees).
- Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities.
- Instructions on what to do if a person with a disability is having difficulty accessing your services.
- The CFC's policies, procedures and practices pertaining to providing accessible customer service to customers with disabilities.
The CFC will provide training as soon as practicable. Training will be provided to new employees, volunteers, agents and/or contractor who deal with the public or act on our behalf (insert when such as, during orientation). Revised training will be provided in the event of changes to legislation, procedures and/or practices. Department Directors will assume responsibility for providing this document to all volunteers during the orientation process.
Record of Training:
The CFC will keep a record of training that includes the dates training was provided and the number of employees who attended the training. Human Resources will create and maintain the appropriate form and records.
Notice of Availability and Format of Documents
The CFC shall notify customers that the documents related to the Accessibility Standard for Customer Service are available upon request and in a format that takes into account the customer's disability. Notification will be given by posting the information in a conspicuous place owned and operated by the CFC, the CFC's website and/or any other reasonable method.
We will also provide appropriate signage at our events. Directors should notify Operations of the requirements.
If you have any questions or concerns about this policy or its related procedures, please contact:
Chief Human Resources Officer, CFC
Canadian Film Centre
2489 Bayview Avenue
Toronto, ON M2L 1A8
This policy and its related procedures will be reviewed as required in the event of legislative changes.
AODA - Multi-Year Accessibility Plan for the Integrated Accessibility Standards Regulation (the “IASR”)
This Multi-Year Accessibility Plan outlines the policies and actions that the Canadian Film Centre (CFC) will put in place to improve opportunities for people with disabilities in accordance with the requirements communicated under the Integrated Accessibility Standards, Ontario Regulation 191/11.
Statement of Commitment
The CFC is an equal opportunity employer and is committed to providing a barrier-free environment that allows all people to maintain their independence and dignity. The CFC will uphold the requirements set forth under the Accessibility for Ontarians with Disabilities Act (2005) and its associated Regulations and strive to meet the needs of individuals with disabilities in a timely and effective manner.
Our Plan supports all disabilities including: physical impairments, sensory impairments, mental impairments, and the aged.
The CFC will by January 1, 2012:
- Develop and implement a company policy to govern how the organization will achieve accessibility.
- Welcome Service Animals.
- Create accessible ways for people to provide feedback.
- Post on our website our commitment to AODA.
- Create a written training manual for current employees, new hires and volunteers.
- Maintain records including dates and signatures to verify completed training.
- Post accessible emergency information to our employees and to the public on our website.
The CFC will by January 1, 2014:
- Create a Multi-Year Accessibility Plan and meet with the Risk Management Committee for ideas and input.
- Make the new website conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level A.
The CFC will by December 31, 2014:
- File an Accessibility Compliance Report.
The CFC will by January 1, 2015:
- Train staff and Volunteers on Ontario’s accessibility laws.
- Provide a mechanism for people with disabilities to provide feedback.
The CFC will by January 1, 2016:
- Make our public information accessible on our website.
- Update employment practices to ensure that people with disabilities are accommodated at all stages of the hiring, development, performance management and retention processes.
- Update the recruitment process and applications across all programs (Media Lab, Features, Television, Music, Acting) and communicate our commitment to accommodating applicants with disabilities
- Create a plan to accommodate a return-to-work for those with disabilities.
The CFC will by January 1, 2017:
- Make redeveloped public spaces accessible as required, including:
- Recreational trails
- Outdoor public use eating areas
- Public outdoor paths of travel
- Parking lots
- Fixed waiting lines
- Waiting areas with fixed seating
The CFC will by December 31, 2017:
- Meet with all employees, on an individual basis to determine personal needs to determine any potential barriers.
- Inform new and existing employees of the CFC’s policies and if necessary provide them with accessible formats and communication supports to do their job effectively.
- File an Accessibility Compliance Report.
The CFC will by December 31, 2018:
- Train our key program mentors and solicit feedback to determine needs of residents.
- Determine what assistive devices or assistance (i.e. APL), within reason, are required and assess the impact on our budget.
- Determine if the service elevator can be upgraded with a call button.
- Train all employees on the Human Rights Code where it relates to persons with disabilities.
The CFC will by January 1, 2021
- Make all websites and web content conform to (WCAG) 2.02 Level AA.
The CFC will by December 31, 2023:
- File an Accessibility Compliance Report
Additional Commitments to Accessibility Include:
The CFC Risk Management Team will conduct a quarterly review to review potential new barriers. This review will be led by the CHRO.
Most of our buildings are barrier free with various degrees of accessibility:
- Norther Dancer Pavilion – barrier free entrance, and washrooms
- Cottage A/B - barrier free entrance and washroom
- Stable – barrier free entrance and washroom
- Main House - barrier free entrance, courtyard and service elevator
- Greenhouse - barrier free entrance and washroom; walkway for partially sighted